4.2 <strong>Solvency</strong> margin4.2.1 Basic principle4.2.1.1 YardsticksGeneral remarksFor life-insurance companies already existing, a significant increase <strong>of</strong> the solvency requirements isgenerally rejected, a moderate increase, however, finds unlimited support. As to the procedures, thereis agreement that separate yardsticks should be defined for the technical risk and the investment risk,that each yardstick should be multiplied by the rate applicable to it (per cent or per mille) and to addup the individual results cumulatively, as before. The result is the total amount <strong>of</strong> the solvency margin.Technical riskAll <strong>of</strong> the delegations take the view that the technical risks (excluding the operating expenses risk)should be evaluated on the basis <strong>of</strong> the capital at risk, and the operating expenses risk should asbefore be evaluated on the basis <strong>of</strong> the mathematical provisions. One delegation thinks that the grosspremiums would also be a suitable yardstick. The working group agrees that premiums as well as themathematical provisions have the disadvantage <strong>of</strong> "penalising" insurance companies who calculateprudently since in both cases a higher index is used as a basis than with imprudently calculatingcompanies. The proposal, however, to apply past administration costs as a yardstick has not beenpursued any further since such a parameter is difficult to define and control.It has been noted, however, that at the moment, standard definitions for both terms, i. e."mathematical provisions" and "risk capital", do not exist yet.The working group discussed at length whether a reference to article 18 <strong>of</strong> the third life insuranceDirective would be sufficient regarding the mathematical provisions, or if a complete definition <strong>of</strong> theterm ‘mathematical provisions’ in accordance with the items mentioned in the insurance accountingdirective is necessary. It was finally agreed to understand ‘mathematical provisions’ to mean at leastthe total <strong>of</strong> the provision for unearned premiums and the life assurance provision referred to inarticles 25 and 27 <strong>of</strong> the insurance accounting directive.The term ‘risk capital’ <strong>of</strong> the first life insurance Directive is then understood to mean the differenceoccurring at the respective point in time between the insurance sum becoming due upon realisation <strong>of</strong>the insured event and/ or in pension insurance the cash value <strong>of</strong> all existing obligations incurred by theundertaking on the one hand, and the available mathematical provisions on the other hand.- 28 -
Investment riskTwo alternative yardsticks are proposed for the investment risk in life insurance, the mathematicalprovisions or, similar to the RBC approach and the European banking regulation, the risk-weightedinvestments. A majority leans towards the method applied up to now, according to which themathematical provisions are considered an adequate yardstick for the investment risk.However, a number <strong>of</strong> delegations consider using the investments themselves as a yardstick, which inthis case would have to be weighted appropriately as is done in banking. To assess the effects <strong>of</strong> atransition in the evaluation basis applied from the liabilities side (mathematical provision) to the assetsside, the life-insurance market in one member country has been examined. For this purpose, theweighting factors were derived from the respective provisions <strong>of</strong> the banking sector (article 6 <strong>of</strong> theCouncil Directive <strong>of</strong> December 18, 1989 on a solvency coefficient for credit institutions,89/ 647/ EEC). This examination shows that taking account <strong>of</strong> all investments including theinvestments <strong>of</strong> the uncommitted assets, a rate <strong>of</strong> 7 % applied to the risk-weighted investments wouldresult in an increase <strong>of</strong> the requirements in life-insurance in this member state by an acceptable rate <strong>of</strong>12 %. It has moreover been noted for selected insurance undertakings showing different attitudestowards risks that, if a different calculation method were to be applied, companies pursuing a ratherlow-risk investment strategy would have to cover a lower solvency margin, and rather venturesomecompanies a higher solvency margin (see examples in annex 11). A point in favour <strong>of</strong> considering theassets side <strong>of</strong> the balance sheet for the solvency calculation is that the investments are the actual riskcarriers. Moreover, the disadvantage associated with applying the mathematical provisions, i. e. anundertaking prudently calculating the mathematical provisions must present a higher solvency than aless prudent competitor, is avoided. In this context it is also important that there is a certain dangerthat undertakings calculating their provisions so that they are just sufficient pursue at the same time arisky investment policy. An approach involving the risk-weighted investments would force suchcompanies to adequately increase their own funds.A point against the approach taken from the banking sector is that insurance undertakings, in contrastto banks, are mainly interested in the liabilities side <strong>of</strong> the balance sheet. Explicitly taking the assetsside into consideration for the solvency calculation is also rejected by a number <strong>of</strong> delegations becausethis does not take account <strong>of</strong> the required balance between the due dates and adequacy <strong>of</strong> thetechnical liabilities and the assets covering them. This danger could be averted by the resilience test(see 2.2.3 above, Matching risk) as part <strong>of</strong> risk prevention, rather than by a higher solvency margin.The risks inherent in investments should therefore be taken into account in the evaluation <strong>of</strong> theprovisions (resilience test), in the amount <strong>of</strong> the technical interest rate or when evaluating theinvestments themselves, but not within solvency. Moreover, in the insurance sector, opposed to thebanking sector, there are detailed investment rules which may no longer be justified if the investmentswere to be risk-weighted. In addition, an undertaking is forced by the proposed approach to follow aninvestment strategy which would consider investments with a low weighting factor only. Also, thedetermination <strong>of</strong> the risk-weightings is considered very subjective and difficult to follow.- 29 -
- Page 9 and 10: ,QWURGXFWLRQSolvency as referred to
- Page 11 and 12: At the same time, the economic coll
- Page 13 and 14: 2.1.2 Technical risksa) Current ris
- Page 15 and 16: Matching riskThe assets of insuranc
- Page 17 and 18: In life insurance premiums must be
- Page 19 and 20: Matching riskThe matching risk can
- Page 21 and 22: However, sufficient experience with
- Page 23 and 24: With respect to the remaining class
- Page 25 and 26: However, these undertakings would n
- Page 27 and 28: first Directive, or in accordance w
- Page 29 and 30: The parameters A, B and C are to be
- Page 31 and 32: The majority of delegations admit t
- Page 33 and 34: Another delegation suggested to all
- Page 35: extent taking account of inflation
- Page 39 and 40: e put into practice. A number of de
- Page 41 and 42: 4.2.2.5 TontinesAt the moment, this
- Page 43 and 44: Moreover, the working group discuss
- Page 45 and 46: 5.2.4 Own funds substitutesOwn fund
- Page 47 and 48: A number of members of the working
- Page 49 and 50: to be at risk. In some member state
- Page 53 and 54: AN N EX 1),1$1&,$/',)),&8/7,(62&&85
- Page 55 and 56: - 47 -- inappropriate capital struc
- Page 57 and 58: - 49 -In terms of frequency of occu
- Page 59: - 51 -Reinsurance riskIn some count
- Page 62 and 63: - 54 -a) Asset risk, C 1:The asset
- Page 64 and 65: - 56 -factors will result in the re
- Page 66 and 67: - 58 -IL i := an average loss rate
- Page 68 and 69: - 60 -First level of intervention (
- Page 71 and 72: - 63 -AN N EX 32:1)81'65(48,5(0(176
- Page 73: - 65 -in the case of balance-sheet
- Page 76 and 77: The value of the liabilities, and p
- Page 78 and 79: - 70 -Enclosure to Annex 4Examples
- Page 81 and 82: - 73 -AN N EX 5$/7(51$7,9(3529,6,21
- Page 83: - 75 -Model calculation CAssumption
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- 78 -Risk of inadequacy of claims
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- 81 -ANNEX 7(;$03/(6)257+(&$/&8/$7
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Example: non-life insurance underta
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- 85 -AN N EX 8$1$/7(51$7,9(0(7+2',
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AN N EX 9(;7(16,212)7+($'',7,9(0(7+
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- 89 -However, the parameters shoul
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In principle, an insurance undertak
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Annex 9 - Enclosure 2Table 2:The ra
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- 97 -ANNEX 11(;$03/(6)257+(&$/&8/$
- Page 107 and 108:
Example: life insurance undertaking
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- 101 -AN N EX 123(50$1(17+($/7+,16